How the Poultry Industry is Grinding Up Workers’ Health and Rights

Juan
(not his real name) was instructed to get back to work after falling
while lifting an 80-pound box of chicken. X-rays later showed two
fractured vertebrae. He was fired, and the employer has not paid any of
his medical bills. (Courtesy of SPLC)Walk through any
supermarket poultry section and you can marvel at the wonders of the
modern food processing industry: antiseptic aisles packed with gleaming,
plump shrink-wrapped chickens, sold at bargain prices under the labels
of trusted agribusiness brands like Tyson and Pilgrim’s. But all that
quality meat doesn’t come cheap: it’s paid for dearly by factory workers
who brave injury, abuse and coercion every day on assembly lines
running at increasingly deadly speeds.

According to newly published research
on Alabama poultry workers by the civil rights group Southern Poverty
Law Center (SPLC), the business model of the sector has sacrificed
health and safety on the factory floor for the Tayloristic efficiency
demanded by American appetites.The supersized industry, which churns out about 50 pounds of chicken
per American stomach annually, dominates many struggling towns in
Alabama, a mostly non-union state, supporting about 10 percent of the
local economy and some 75,000 jobs. But according to the SPLC’s
researchers, the production line is butchering workers' health:

Nearly three-quarters of the poultry workers interviewed for this
report described suffering some type of significant work-related injury
or illness. In spite of many factors that lead to undercounting of
injuries in poultry plants, the U.S. Occupational Safety and Health
Administration (OSHA) reported an injury rate of 5.9 percent for poultry
processing workers in 2010, a rate that is more than 50 percent higher
than the 3.8 percent injury rate for all U.S. workers.

Alabama workers interviewed by the SPLC reported being routinely
subjected to unsafe working conditions that led to severe health
threats, from repetitive stress injuries to respiratory issues to
chemical burns. Adding insult to injury, employers often ignored
workers’ debilitating problems or punished them for asserting their
rights. Evoking images reminiscent of Upton Sinclair’s century-old
expose on the meat-packing industry The Jungle, workers reported that
problems like crippling hand pain would be diverted to the company
nurse, rather than more intensive care by an outside doctor. Others were
fired before they could become more of a liability. One worker, a black woman in her 30s, recounted in an interview being pressured to shield her company from responsibility for her injury:

“I shouldn’t say it’s work-related. If I say my pain comes from
something I did at work, then I will be laid off without pay and three
days later get fired. So, when I go to the nurse I tell her that I hurt
my hands at home.”

In towns that lack decent job opportunities outside of the poultry
industry, these workers face an oppressive workplace culture that
undermines not only their health but their dignity. Workers reported
“being discouraged from reporting work-related injuries, enduring
constant pain and even choosing to urinate on themselves rather than
invite the wrath of a supervisor by leaving the processing line for a
restroom break.” Conditions may soon worsen, the SPLC notes, because the Department of Agriculture is seeking to alter regulations to allow even faster line speeds. That means the already frenzied pace of production--whipping
bird carcasses into hermetically sealed flesh pellets in a matter of
seconds--might speed up even more under a controversial set of proposed
changes to plant inspection protocols.The planned reforms have been criticized as counterproductive because
they transfer control of inspections from federal inspectors to company
employees. The revamped inspection process would, according to critics,
both give corporations more power to regulate their own henhouse while
accelerating the already frighteningly hectic pace of production. Some USDA inspectors have criticized the proposal, warning that
with the combination of sped-up lines and company-controlled oversight,
these industry-backed efforts to “modernize” the production chain may
create more safety risks. So safety standards for both consumers and
workers might be further weakened. (Industry representatives dispute the SPLC's research, insisting that the proposal would not harm safety standards.)Underlying labor injustices have exacerbated the immediate workplace
hazards. The mostly black and Latino workforce, which includes many
documented and undocumented immigrants, generally have little recourse
against abusive employers. Many saw their pay arbitrarily cut by
deductions for housing expenses and other fees. Meanwhile, for female
workers, sexual harassment was a commonly reported issue. Harsh immigration enforcement laws, which were recently tightened by state legislation that
seeks to further criminalize undocumented Latino workers, has made them
even more economically insecure and socially marginalized.One structural problem making poultry workers especially vulnerable, the researchers argue,
is that despite some general occupational safety guidelines for poultry
plants, OSHA “has no set of mandatory guidelines tailored to protect
poultry processing workers,” which constrains workers' ability to take
legal action against unsafe working conditions or unfair treatment.The report's author, SPLC advocate Tom Fritzsche, says that while
OSHA can enforce general workplace protections, regulatory gaps
nonetheless enable the industry to structure its labor system around
loophole-ridden standards for food production, which are not focused on
worker safety. "This specific [line speed] rule from USDA is not really
intended originally as a worker protection standard... The speed that
they currently run at is based more on whether the inspectors can see
the chickens, rather than how the workers can do the work safely," he
says. As a result of these regulatory lapses, "We've kind of ended up in
a world where this is the only limit on speeds."Until state and federal regulators start prioritizing workers' labor rights and health needs,
the unsafe work environment, Fritzsche adds, “ultimately comes from the
fact that the whole industry is just operating in this kind of race to
produce as many chickens as they can in as little amount of time as they
can. And so it affects every aspect of the worker's job.”But all those bitter hardships are stowed far away from the millions
of super-clean, ultra-cheap drumsticks that will end up on American
dinner tables tonight. Countless consumers will enjoy their meals
without any conception of how perfectly the poultry industry masks the
true price of its brutal efficiency.

SUMMARY: Based on the scientific uncertainty surrounding both the
molecular characterization of genetically engineered (GE) crops as well
as the detection of potential allergenicity, there is more than enough
uncertainty to decide to require labeling of foods produced via GE as a
risk management measure as a way to identify unintended health effects
that may occur post approval. If foods are not labeled as to GE status,
it would be very difficult to even identify an unexpected health effect
resulting from a GE food.

Dear Council Members:
I am writing to submit scientific evidence which strongly supports the
intent of Resolutions 508 and 509 Supporting Federal Legislation and/or
Regulations that Require Clearly Labeling Food with Genetically
Engineered Ingredients. Consumer Union1 supports mandatory labeling for
foods produced with genetically engineered (GE) ingredients for a number
of reasons.

1.There has been global agreement that
genetically engineered foods are different than conventionally bred
foods and that all genetically engineered foods should be required to go
through a safety assessment prior to approval. Codex Alimentarius is
the food safety standards organization of the United Nations, and is
jointly run by the Food and Agriculture Organization (FAO) and the World
Health Organization (WHO). From 2000 – 2008, there were two rounds of
the Codex Alimentarius Ad Hoc Intergovernmental Task Force on Foods
Derived from Biotechnology. This Task Force developed a number of
documents, including a Guideline for the Conduct of Food Safety
Assessment of Foods Derived from Recombinant-DNA Plants (CAC/GL 45,
2003); there are separate Guidelines for GE animals and GE
microorganisms, as well. The World Trade Organization (WTO) considers
that, in terms of food safety, the standards or guidelines of Codex
Alimentarius are deemed the global science-based standard and, thus,
immune to trade challenges, i.e. they are not considered to be a
“non-tariff trade barrier.”

The reason for two rounds of the Codex Alimentarius Ad Hoc
Intergovernmental Task Force on Foods Derived from Biotechnology came as
a result of a global agreement that genetic engineering is a process
that is sufficiently different from conventional breeding that foods
developed via genetic engineering should go through a safety assessment
before such foods are allowed on the market. For information on the ways
genetic engineering differs from conventional breeding, see Hansen,
2000.

Last year, after more than 15 years of debate, the Codex Committee on
Food Labeling agreed to forward a document on labeling of GE foods to
the Codex Alimentarius Commission for approval. Last July, at the
conclusion of the meeting of the Codex Alimentarius Commission, the
World Health Organization News put out a letter to journalists, noting
that the ”Codex Alimentarius Commission has stated that governments are
free to decide on whether and how to label foods derived from modern
biotechnology, including foods containing genetically-modified
organisms. The labeling should be done in conformity with the text
approved by the Codex Commission, to avoid a potential trade barrier.
The decision, which will help inform consumers’ choices regarding
genetically-modified foodstuffs, was taken at the 34th Session of the
Commission, held in Geneva from 4-9 July 2011. More than 600 delegates
from 145 of the 184 member countries, UN, inter-governmental and
non-governmental organizations attended.”

Unlike all other developed countries, the US Food and Drug
Administration (FDA) does not require safety testing for GE plants. The
FDA’s original policy on GE (or GM, for genetically modified) plants was
introduced at a press conference at an industry gathering on May 28,
1992 by then Vice-President Dan Quayle as a de-regulatory initiative.
The policy was based on the notion “that the new techniques [e.g.
genetic engineering] are extensions at the molecular level of
traditional methods and will be used to achieve the same goals as
pursued with traditional plant breeding,” and therefore should be
regulated in the same way. In other words, no requirement for human
safety testing; instead there are “voluntary safety consultations.”

The lack of adequate safety testing can be seen in the letter FDA sends
to the company after completion of a “safety consultation.” For example,
the letter sent to Monsanto on September 25, 1996 about one of their
first Bt-corn varieties, MON810, states, “Based on the safety and
nutritional assessment you have conducted, it is our understanding that
Monsanto has concluded that corn grain and forage derived from the new
variety are not materially different in composition, safety, or other
relevant parameters from corn grain and forage currently on the market,
and that they do not raise issues that would require premarket review or
approval by FDA” bold added. Note that FDA does not state its own
opinion about
the safety of this crop; it only states what the company believes. The
letters for all 84 “safety consultations” done since the Flavr Savr
tomato contain basically the same language. This clearly shows that the
FDA does not conduct safety assessments.

Other scientists have noted the lack of proper safety testing. For
example, Dr. Belinda Martineau, the scientist who conducted the safety
studies on the first GE plant, the Flavr Savr tomato (engineered for
long shelf life) at Calgene, points out in her book First Fruit: the
Creation of the Flavr Savr Tomato and the Birth of Biotech Foods:
“Rather than personal opinion, the scientific community should give the
public facts, hard facts; the results of studies that indicate these
foods are safe to eat and that growing them on a large scale will not
cause environmental damage. Scientists and regulators throughout the ag
biotech industry agree that more public education about genetic
engineering research is necessary, but, thus far, few have provided much
information beyond how the technology works and the wondrous things
that might be done with it. . . . And simply proclaiming that ‘these
foods are safe and there is no scientific evidence to the contrary’ is
not the same as saying ‘extensive tests have been conducted and here are
the results.’ In fact, without further elaboration, ‘no scientific
evidence to the contrary’ could be construed as ‘no scientific evidence,
period.’ ” italics added.

Since the 1992 Statement of Policy on genetically engineered food, FDA
has admitted that its original policy was based on a false notion. In
2001, the FDA proposed requiring companies to notify the government at
least 120 days before commercializing a transgenic plant variety. As
part of that proposed rule, the FDA admits that insertional mutagenesis
is a problem and suggests requiring data on each separate transformation
event: "[B]ecause some rDNA-induced unintended changes are specific to a
transformational event (e.g. those resulting from insertional
mutagenesis), FDA believes that it needs to be provided with information
about foods from all separate transformational events, even when the
agency has been provided with information about foods from rDNA-modified
plants with the same intended trait and has had no questions about such
foods. In contrast, the agency does not believe that it needs to
receive information about foods from plants derived through narrow
crosses [e.g. traditional breeding]" italics added (FR 66(12), pg.
4711). In other words, FDA has admitted that there is a difference
between GE and traditional breeding. In spite of this, FDA is still
following the 1992 policy rather than the 2001 policy.

Global agreement has been reached on what constitutes proper safety
assessment of foods derived from GE plants, yet such suggested studies
have not been carried out on GE Bt corn (or any other GE crop approved
in the US). In 2003, the Codex Alimentarius Ad Hoc Task Force on Foods
Derived from Biotechnology reached agreement on a “Guideline for the
conduct of food safety assessment of foods derived from recombinant-DNA
plants.” This Guideline was formally adopted by the full Codex
Alimentarius Commission in 2003, and was updated in 2008. This is
important because in the case of trade disputes, the World Trade
Organization considers that, in terms of food safety, the standards or
guidelines of Codex Alimentarius are deemed the global science-based
standard and, thus, immune to trade challenges, i.e. they are not
considered to be a “non-tariff trade barrier.” At present, none of the
GE plants on sale in the US can meet this standard.

Since the US does not require safety assessments of GE plants, while the
Codex Alimentarius Guideline for the Conduct of Food Safety Assessment
of Foods Derived from Recombinant-DNA Plants states that such a food
safety assessment should be done, this means the US cannot meet the
global standards for safety assessment of GE foods. Consequently,
countries that require food safety assessments for GE foods could block
shipments of such GE foods from the US without fear of losing a WTO
challenge.

We believe that the US should require safety assessments on foods
derived from GE organisms, and that those safety assessments should be
consistent with the guidelines developed by the Codex Alimentarius Ad
Hoc Intergovernmental Task Force on Foods Derived from Biotechnology so
that US food products are not potentially subject to a WTO challenge
from another country.

2. Significant scientific uncertainty
exists in the risk analysis of foods derived from GE and this is
recognized in the Codex. In fact, the Guideline for the Conduct of Food
Safety Assessment of Foods Derived from Recombinant-DNA Plants has a
whole section on unintended effects which clearly states that they can
have an unintended effect on human health: “Unintended effects due to
genetic modification may be subdivided into two groups: those that are
“predictable” and those that are “unexpected” . . . A variety of data
and information are necessary to assess unintended effects because no
individual test can detect all possible unintended effects or identify,
with certainty, those relevant to human health.” (paras 16 and 17,
CAG/GL 45-2003). Furthermore, this section recognizes that the
unintended effects could also be caused by changes in genes that are
expressed at the molecular level and how the gene products are
processed: “Molecular biological and biochemical techniques (that) can
also be used to analyze potential changes at the level of gene
transcription and message translation that could lead to unintended
effects” (para 16, CAG/GL 45-2003).

3. Labeling of GE food can serve as a
risk management measure to deal with scientific uncertainty. This would
be consistent with the recommendations developed by the Codex
Alimentarius Ad Hoc Intergovernmental Task Force on Foods Derived from
Modern Biotechnology and adopted by the Codex Alimentarius Commission in
2003. The Principles for the Risk Analysis of Foods Derived from Modern
Biotechnology (CAC/GL 44—2003) clearly state that labeling can be used
as a risk management option to deal with scientific uncertainties
associated with the risk assessment of GE foods: “18. Risk managers
should take into account the uncertainties in the risk assessment and
implement appropriate measures to manage these uncertainties. 19. Risk
management measures may include, as appropriate, food labeling,
conditions for market approval and post-market monitoring.”

If there are unexpected adverse health effects that happen as a result
of GE, then labeling could serve as a risk management mechanism that
would allow us to track such health problems if they arose. If a food
with GE ingredients is not labeled as such, and that food causes an
adverse health effect, such as an allergic reaction, there would be
virtually no way to determine that the GE process was linked to the
adverse health effect. For example, suppose a company decides to insert a
synthetic gene, which codes for a modified protein, into tomatoes.
Suppose that the novel protein causes a strong but delayed (say by 24
hours) allergic reaction (e.g. serious rash, upset stomach, or
anaphylactic shock) in some relatively small subset of the population.
To start with, doctors would have an extremely difficult time
identifying the source of the problem. If the offending tomato variety
is not very prevalent (i.e. does not have a large market share), then
the regular allergy test, making a list of all foods eaten in the last
24 hours, might not uncover the tomato as the source of the problem (the
person would have to obtain and eat the offending tomato variety a
second time and get the same reaction). It might well take large numbers
of people being adversely affected and having the offending tomato
variety be a large share of the market before there would be any hope of
figuring out what was causing the problem.

Even if the food has undergone rigorous premarket safety testing,
scientific uncertainties remain associated with the risk analysis. In
addition, when a large population (in the millions or tens of millions)
is exposed to a GE food, rare unexpected health problems can appear.
Take the case of Vioxx, a drug that was found to be safe in premarket
testing but had to be removed from the market after adverse health
effects were seen when the drug was used by large numbers of people.
Because these drugs are labeled, doctors are able to associate the
unexpected health problem with the specific drugs. With GE foods,
labeling would serve a similar purpose.

In addition to FDA not requiring any premarket safety testing, there is
virtually no independent safety testing of these crops in the US due to
intellectual property rights. When farmers buy GE seed in the US, they
invariably must sign a product stewardship agreement which forbids them
from giving such seeds to researchers.In addition, researchers must get
permission from the biotech companies before they can do research, which
means there is a paucity of independent research. Scientists have even
been threatened with legal action if they revealed information obtained
via freedom-of-information. In early 2009 26 public sector scientists in
the US took the unprecedented step of writing to the US Environmental
Protection Agency (EPA) protesting that “as a result of restricted
access, no truly independent research can be legally conducted on many
critical questions regarding the technology.” As a result, the editors
of Scientific American published a perspective stating that “we also
believe food safety and environmental protection depend on making plant
products available to regular scientific scrutiny. Agricultural
technology companies should therefore immediately remove the restriction
on research from their end-user agreements.” We concur and believe that
only truly independent safety tests will give us an answer about the
safety of GE foods. In the meantime, it’s crucial that GE foods be
labeled as a risk management measure to deal with scientific
uncertainty.

4. We believe that consumers have a
right to know what is in the food they eat. A number of polls from 1995
to 2011 have found that between 70% and 95% of people polled supported
mandatory labeling. “Information of material importance” to consumers is
far broader than just “changes in the organoleptic, nutritional or
functional properties” of a food. The fact that more than 850,000 people
have sent comments to the FDA in support of a citizen’s petition asking
FDA to require labeling of GE foods, shows that consumers
overwhelmingly want food from GE sources to be labeled as such. In
addition, on March 12, 2012, US Senator Barbara Boxer and Congressman
Peter DeFazio joined with 53 other Senate and House lawmakers in sending
a letter urging the FDA to require the labeling of GE foods.

FDA has tried to argue that they don’t have the authority to label GE
foods unless there is a “material change” in the food, which FDA defines
as “change in the organoleptic, nutritional or functional properties”
of the food that is not obvious to the consumer at the point of
purchase. We strongly disagree with FDA and feel that they are trying to
ignore their own history. In the past FDA has required labeling under
the “material fact” analysis that did not entail a change in nutritional
value, organoleptic properties, or functional characteristics of a
food. FDA’s authority to require labeling of all foods derives, in part
from section 201(n) and 403(a)(1) of the Federal Food Drug and Cosmetic
Act. A label is considered “misleading” if it “fails to reveal facts
that are material in light of representations made. . .” bold added. FDA
articulated this position in the 1986 final rule that required labeling
of irradiated foods, even though the FDA had ruled that irradiated
foods were safe. FDA stated in this final rule on food irradiation that
the large number of respondents who asked for labeling of retail
products was one factor indicative of the materiality of food
irradiation: “Whether information is material under section 201(n) of
the act depends not on the abstract worth of the information but on
whether consumers view such information as important and whether the
omission of label information may mislead a consumer. The large number
of consumer comments requesting retail labeling attest to the
significance placed on such labeling by consumers” emphasis added. Thus,
materiality clearly does not always include “some change in nutritional
value, organoleptic properties, or functional characteristics” of the
food.

Material facts other than material changes have long been required for
other reasons that are important to consumers. Labeling the source of
protein hydrolysates was required because of the concern of vegetarians
and observant Jews and Muslims. As the FDA stated, “the food source of a
protein hydrolysate is information of material importance for a person
who desires to avoid certain foods for religious or cultural reasons.”
Thus, “information of material importance” to a consumer is not simply
restricted to “information about the characteristics of a food.”

In 2007, FDA proposed a revision to their labeling requirements for
irradiated foods, such that labeling would only be required on those
irradiated foods in which the irradiation has lead to a “material
change”—defined as a “change in the organoleptic, nutritional or
functional properties”—in the food that is not obvious to the consumer
at the point of purchase. Thus, not all irradiated food would be
required to be labeled. This proposed revision to the irradiation
labeling standard went nowhere. However, this attempted weakening of the
food irradiation labeling standard clearly demonstrates that FDA is now
trying to narrow the concept of “materiality,” so as to avoid the
labeling of GE foods.

A number of recent scientific studies have pointed out unexpected
effects in genetically engineered crops and have shown that they can
lead to potential adverse health effects:

• GE plant materials are finding their way into the human body. A study
done by Canadian scientists and published last year was very disturbing.
The study involved 30 pregnant and 39 non-pregnant women in Quebec,
Canad Blood was taken from women and from fetal cord blood and tested
for 3 pesticides associated with GM: glyphosate, glufosinate, and
Cry1Ab. The surprising finding was that Cry1Ab was detected in 93% and
80% of maternal and fetal blood samples, respectively and in 69% of
tested blood samples from nonpregnant women. The scientists noted that
“trace amounts of the Cry1Ab toxin were detected in the gastrointestinal
contents of livestock fed on GM corn, raising concerns about this toxin
in insect-resistant GM crops; [suggesting] (1) that these toxins may
not be effectively eliminated in humans and (2) there may be a high risk
of exposure through consumption of contaminated meat.” They concluded,
“To our knowledge, this is the first study to highlight the presence of
pesticides-associated genetically modified foods in maternal, fetal and
nonpregnant women’s blood. 3-MPPA and Cry1Ab toxins are clearly
detectable and appear to cross the placenta to the fetus. Given the
potential toxicity of these environmental pollutants and the fragility
of the fetus, more studies are needed, particularly those using the
placental transfer approach.”

• A major food safety concern for GE plants is allergenicity. In 2001,
the report of a Joint Food and Agriculture Organization/World Health
Organization (FAO/WHO) Expert Consultation on Allergenicity of Foods
Derived from Biotechnology, held at WHO headquarters in Rome, laid out a
detailed protocol (a decision tree) for evaluating the allergenicity of
GE foods. None of the GE crops, including GE corn, on the market in the
U.S. have been assessed using such a protocol.

• Various types of scientific evidence suggest that Bt corn may contain a
transgenic allergen. Bt corn contains various modified endotoxins from
the soil bacterium Bacillus thuringiensis (Bt). These δ-endotoxins are
called Cry proteins, in particular Cry1Ab or Cry1Ac. A study of
farmworkers who worked in onion fields where foliar Bt sprays were used
found that 2 of them contained antibodies to the δ-endotoxins, Cry1Ab
and/or Cry1Ac, consistent with an allergy. A survey of Bt cotton farmers
in India done by local doctors found that numerous Bt cotton farmers,
as well as workers in a ginning factory, had symptoms consistent with an
allergic reaction to Bt cotton within a year of the introduction of Bt
cotton in the region.

• One of the endotoxins found in GE corn, Cry1Ac, has been found to have
sequence similarity to a known human allergen. One of the first steps
in assessing the allergic potential of a protein (most allergens are
proteins) is to determine if it has similarity in amino acid sequence to
a known allergen. A paper published in 1998 by the head of FDA’s own
biotechnology studies branch, Dr. Steven Gendel, found significant amino
acid sequence similarity between Cry1Ab and Cry1Ac (found in Bt maize
and Bt cotton) and vitellogenin, the main precursor to egg yolk protein
and a known allergen, as well as between Cry3A (Bt potatoes) and
β-lactoglobulin, a major milk allergen.

• Scientific studies also show Cry1Ac has a strong effect on the immune
system as well as being a potent adjuvant. A series of five studies
carried out by a team of scientists from two Mexican universities and
from Cuba have suggested that the Cry1Ac protein has immunogenic and
allergenic properties. A mouse study demonstrated that the Cry1Ac was a
potent systemic and mucosal adjuvant: “We conclude that Cry1Ac is a
mucosal and systemic adjuvant as potent as CT [cholera toxin] which
enhances mostly serum and intestinal IgG antibody responses”. Another
mouse study which further characterized the mucosal and systemic immune
response induced in mice “confirm[ed] that the Cry1Ac protoxin is a
potent immunogen able to induce a specific immune response in the
mucosal tissue, which has not been observed in response to most other
proteins” commercialization of food elaborated with self-insecticide
transgenic plants it is necessary to perform toxocological tests to
demonstrate the safety of Cry1A proteins for the mucosal tissue and for
the immunological system of animals.” Such tests have never been carried
out on GE Bt-corn.

• Corn allergen gene turned on as result of genetic engineering. A
carefully designed study involved growing Monsanto’s Bt corn varieties,
MON 810, in a growth chamber along with its near isoline (corn variety
engineered to produce MON 810). Since MON 810 and its near isoline are
grown in the same environment, the only difference in the plants will be
due to the effect of genetic engineering. This was a proteomic study,
which is a study of the expressed proteins, not just of the protein(s)
expressed as a result of genetic engineering. Proteomic studies are a
good way to detect unintended effects associated with genetic
engineering, particularly the disruptive effects due to the random
insertion of a transgene. The study found that 43 proteins in the MON
810 plants were significantly disrupted, compared to the non-GE near
isoline. As the study notes, “a newly expressed spot (SSP 6711)
corresponding to a 50 dDa gamma zein, a well-known corn allergenic
protein, has been detected. Moreover, as a major concern, a number of
seed storage proteins (such as globulins and vicilin-like embryo storage
proteins) exhibited truncated forms having molecular masses
significantly lower than the native ones.” The safety implications of
the truncated seed storage proteins are unknown, as no feeding study was
done. So, this study demonstrates that the process of genetic
engineering turned on a known corn allergen gene that is normally turned
off as well as caused changes to the main proteins found in the seed.

• Bt corn may cause adverse effects on gut and peripheral immune
response. A carefully designed study (MON 810 and near isoline grown
simultaneously in neighboring fields in Landriano, Italy, to control for
environmental effects) done by Italian scientists involved feeding a
diet containing MON 810 or its near isoline to mice in vulnerable
conditions, e.g. weaning and old mice, and looking at a variety of
measures of the gut and peripheral immune response. The main finding was
that “compared to the control maize, MON810 maize induced alterations
in the percentage of T and B cells and of CD4+, CD8+, γδT, and αβT
subpopulations of weaning and old mice fed for 30 or 90 days,
respectively, at the gut and peripheral sites. An increase of serum
IL-6, IL-13, IL-12p70, and MIP-1β after MON810 feeding was also found.
These results suggest the importance of the gut and peripheral immune
response to GM crop ingestion as well as the age of the consumer in the
GMO safety evaluation” bold added.

• A meta-analysis of feeding studies involving GE crops suggests health
problems and that longer term studies are needed. A carefully designed
meta-analysis was done of 19 published studies involving mammals fed GE
corn or soy. The meta-analysis also included the raw data from a number
of 90-day-long feeding studies that were obtained as a result of court
action or official requests. The data included biochemical blood and
urine parameters of mammals eating GE crops with numerous organ weights
and histopathology findings. meta-analysis of all the in vivo studies
found that the majority of statistically significant results came from
parameters involving the liver or kidney. The authors conclude that
longer-duration tests are needed, noting that “90-dtests are
insufficient to evaluate chronic toxicity, and the signs highlighted in
the kidneys and livers could be the onset of chronic diseases. However,
no minimal length for the tests is yet obligatory for any of the GMOs
cultivated on a large scale, and this is socially unacceptable in terms
of consumer health protecWe are suggesting that the studies should be
improved and prolonged, as well asbeing made compulsory, and that the
sexual hormones should be assessed toomoreover, reproductive and
multigenerational studies ought to be conducted too.”

• A 2005 animal study on transgenic peas found that the genetic
engineering process unexpectedly turned a protein that is relatively
“safe” into one that causes adverse health effects and increased the
potential for adverse effects in other proteins. A group of Australian
scientists looked at the transfer of a gene from beans into peas. The
gene codes for a protein, a-amylase inhibitor (aAI), that confers
resistance to certain weevil pests. The aAI in raw beans inhibits the
action of amylase, an enzyme that degrades starch. So aAI in raw beans
can cause gastrointestinal problems in humans. When beans are cooked,
the aAI is easily digested and causes no problems. However, when the
gene for aAI was inserted into peas, the resultant protein had the same
amino acid sequence as the bean aAI, yet the structure of the protein
had been subtly altered (through a process called post-translational
processing), causing an immunological reaction in mice fed the
transgenic peas, but not in mice fed normal beans. The
adverse/immunological reaction to the transgenic pea aAI was not
mitigated by boiling the peas. The mice fed transgenic peas, in addition
to developing an immunological reaction to the pea aAI, also developed
an immunological reaction to a number of proteins normally found in
peas; mice fed these same proteins from non-engineered peas developed a
far smaller immunological response, thus demonstrating that the
transgenic pea aAI acts as an adjuvant to increase the immunogenicity of
native pea proteins.

This new study involving aAI is extremely important. This study found
that moving the same gene between two relatively closely related plants
(common beans and peas) can result in a protein that, although it
contains the exact same amino acid sequence, is relatively safe in the
donor plant (common beans), but is potentially harmful in the recipient
plant (peas) and can increase the potential hazardousness of other
proteins found in peas. These are all clearly unintended and unexpected
effects that clearly result in an adverse health effect.

• New data confirm unintended and unexpected effect from genetic
engineering. Other studies in the last 5 years have found all sorts of
unexpected changes/effects in GE crops. A detailed molecular
characterization of various GE crops (three different Bt maizes, an
herbicide-tolerant maize, RoundUp Ready soybean, and a male-sterile
canola) currently on the market, done in Belgium, has shown that of the
transgenic lines looked at, all but one were found to have differences
in the molecular characterization in products on the market compared to
the original structure reported by the company. Except for the canola,
all these reports found that the structure (e.g. molecular
characterization) of transgenic inserts as reported by the companies in
their initial submission were different than the structure found in
subsequent studies. The differences in structure involved rearranged
inserts, partial copies of genes inserted, multiple copies of transgenes
inserted, scrambling of DNA near the border of the transgenic inserts,
etc., suggesting that the transgenic lines are unstable and/or more
likely to result in unintended effects. In fact, in virtually all the
cases, the SBB/IPH recommends that further analysis “should be done to
determine the presence of chimaeric open reading frames in the border
integration sequences”, e.g. an analysis should be done to see if there
are any unexpected proteins being produced.

• A paper reviewing the food safety issues associated with genetically
engineered crops listed a range of documented unintended effects and
concluded that “The development and validation of new profiling methods
such as DNA microarray technology, proteomics, and metabolomics for the
identification and characterization of unintended effects, which may
occur as a result of the genetic modification, is recommended.”

• An Annex to the Codex Plant Guideline on the assessment of possible
allergenicity states that no definitive test exists to accurately
predict allergenicity of a given protein: “At present, there is no
definitive test that can be relied upon to predict allergic response in
humans to a newly expressed protein.” So there is scientific uncertainty
around assessment of potential allergenicity of foods derived from
GE/GM. Furthermore, a study done by Dutch scientists, using a modified,
and more conservative, methodology for screening transgenic proteins for
potential allergenicity (e.g. the analysis of sequence homology to
known food and environmental allergens) as laid out in the Joint FAO/WHO
Expert Consultation on Allergenicity of Foods Derived from
Biotechnology (January, 2001), found that a number of transgenic
proteins have significant sequence homology to known allergens and
recommended further study for a number of these proteins: “Many
transgenic proteins have identical stretches of six or seven amino acids
in common with allergenic proteins. Most identical stretches are likely
to be false positives. As shown in this study, identical stretches can
be further screened for relevance by comparison with linear IgE-binding
epitopes described in the literature. In the absence of literature
values on epitopes, antigenicity prediction by computer aids to select
potential antibody binding sites that will need verification of IgE
binding by sera tests. Finally, the positive outcomes of this approach
warrant [papaya ringspot virus coat protein, acetolactate synthase GH50,
and glyphosate oxidoreductase] further clinical testing for potential
allergenicity”. Another study done by Dr. Steven Gendel of the US Food
and Drug Administration found that there was significant sequence
similarity between a gene in Bt maize and Bt cotton (e.g. Cry1Ab or
Cry1Ac) and an egg yolk allergen and recommended further study: “the
similarity between Cry1A(b) and vitellogenin might be sufficient to
warrant additional evaluation.”

While science demonstrates the need to track potential health impacts of
genetically engineered food, there is also broad support for labeling
genetically engineered food as indicated by the following endorsements
by the public health, nursing, medical and healthcare communities:

--In 2001, the American Public Health Association passed a resolution
entitled Support of the Labeling of Genetically Modified Foods which
"Resolves taht APHA declare its support that any food product containing
genetically modified organisms be so labeled."

--In 2008, the American Nurses Association adopted a resolution on
Healthy Food in Health Care, which specifically, "Supports the public's
right to know through support of appropriate food labeling including
country-of-origin and genetic modification..."

(Authors listed below) (Traduction Francaise)A new paper by the French group of Gilles-Eric Seralini describes
harmful effects on rats fed diets containing genetically modified maize
(variety NK603), with and without the herbicide Roundup, as well as
Roundup alone. This peer-reviewed study (Seralini et al., 2012),
has been criticized by some scientists whose views have been widely
reported in the popular press (Carmen, 2012; Mestel, 2012; Revkin, 2012;
Worstall, 2012). Seralini et al. (2012) extends the work of other
studies demonstrating toxicity and/or endocrine-based impacts of Roundup
(Gaivão et al., 2012; Kelly et al., 2010; Paganelli et al., 2010;
Romano et al., 2012), as reviewed by Antoniou et al. (2010).The Seralini publication, and resultant media attention, raise the
profile of fundamental challenges faced by science in a world
increasingly dominated by corporate influence. These challenges are
important for all of science but are rarely discussed in scientific
venues.